TagACC(1534)

This document is a declaration by environmental scientist Dyanne Sheldon, submitted in support of the Airport Communities Coalition's motion for a stay in a Washington State Pollution Control Hearings Board case challenging permits issued to the Port of Seattle. Sheldon outlines her extensive background as a wetland ecologist and land-use planner, including her role in creating King County's pioneering wetland management program in the early 1980s. The case centers on a Section 401 Water Quality Certification and Coastal Zone Management Act concurrency statement issued to the Port of Seattle in connection with Sea-Tac Airport expansion activities.

This 2002 legal declaration by wetland scientist Dyanne Sheldon challenges the adequacy of environmental protections attached to a Washington State Department of Ecology water quality certification related to Sea-Tac Airport expansion. Sheldon argues that the groundwater and wetland performance standards required under the 401 Certification are too vague and scientifically flawed to reliably measure success or failure, citing problems such as undefined 'normal rainfall' baselines and an over-reliance on qualitative wetland plant ratings from the 1980s. The declaration was submitted in support of the Airport Communities Coalition's motion for a stay of the certification before the Washington Pollution Control Hearings Board.

This legal document is part of a Pollution Control Hearings Board case in which the Airport Communities Coalition (ACC) challenged the Port of Seattle and the Washington State Department of Ecology over environmental concerns related to Seattle-Tacoma International Airport. The document lists scientific references and studies relied upon by ACC's expert witnesses, covering topics such as the effects of airport deicing chemicals on water quality, dissolved oxygen levels in receiving streams, toxicity to aquatic life including salmon and trout, and fluoride impacts on fish. The referenced research was used to support ACC's claims about the environmental impact of airport operations on surrounding waterways and ecosystems.

This legal declaration by William A. Rozeboom, filed before Washington State's Pollution Control Hearings Board, challenges the Port of Seattle and the Department of Ecology over their environmental review of Sea-Tac Airport expansion. Rozeboom disputes the adequacy of water flow modeling used to assess impacts on Walker and Des Moines Creeks, argues that wastewater system effects on stream flow were improperly ignored, and contends that the proposed mitigation conditions in Ecology's 401 Certification are insufficient. He also challenges claims that the Port fully complied with King County's Surface Water Design Manual, noting the Port exempted itself from key drainage review requirements.

A February 2002 letter from Marten Brown attorneys transmits a CD-ROM of data files and related emails from Pacific Groundwater Group (PGG) to opposing counsel in the case ACC v. Port of Seattle. The materials include technical data and correspondence relied upon by expert Charles Ellingson and PGG in forming their opinions and conclusions. Supporting emails from October 2001 detail groundwater inflow and surface runoff modeling data exchanged between consultants Joe Brascher and PGG.

This 2002 legal document is a supplemental response filed by the Airport Communities Coalition (ACC) in a Pollution Control Hearings Board case against the Washington State Department of Ecology and the Port of Seattle, related to the expansion of Seattle-Tacoma International Airport. It lists technical documents and expert references relied upon by ACC's witnesses, covering topics such as hydraulics, biology, and geotechnical engineering related to the proposed third runway project. The filing also summarizes the prior trial testimony experience of expert witnesses retained by the ACC.

Deposition upon oral examination of Thomas Luster, taken February 1, 2002, in PCHB No. 01-160, Airport Communities Coalition (ACC) v. Department of Ecology and Port Of Seattle. Luster, represented by Richard A. Smith of Smith & Lowney, was deposed by Gillis E. Reavis (Marten Brown) for Port Of Seattle and Thomas J. Young (Assistant Attorney

Washington State Department of Ecology Shorelands & Environmental Assistance Program study (Publication No. 02-06-009, AR 031007) authored by Patricia Johnson, Dana L. Mock, Andy McMillan, Lauren Driscoll, and Tom Hruby. Phase 2 evaluation of wetland mitigation success across 24 projects in Washington State, published February 2002. Companion document Appendix F (publication #02-06-010) contains individual project

This document, labeled Exhibit E, contains photographs taken on January 31, 2002 of the Vacca Farm site, showing various land features including areas designated as Prior Converted Cropland, farmed wetlands, and Wetland A1. The photos document the site's vegetation and water features, including a close-up of wetland plants and a view of Miller Creek looking west across Wetland A1. The images appear to be part of an environmental or land-use assessment record related to the Vacca Farm property near Des Moines Way.

This January 31, 2002 letter from Foster Pepper & Shefelman attorneys transmits the Port of Seattle's supplemental response to an interrogatory filed by the Airport Communities Coalition (ACC), listing the prior expert-witness experience of the Port's designated witnesses. The document covers experts in areas such as groundwater hydrology, computer modeling of land development impacts, and FAA obstacle clearance standards, submitted in connection with the case Airport Communities Coalition v. State of Washington Department of Ecology and the Port of Seattle (PCHB No. 01-160). It is part of the administrative record related to disputes over Sea-Tac Airport's environmental and operational practices.